About EthicsPoint and the Speak Up Line

Reporting – General

Reporting Security & Confidentiality

Tips & Best Practices

Other issues

What is the EthicsPoint Speak Up Line?

The EthicsPoint Speak Up Line is a comprehensive and confidential reporting service provided by NAVEX that enables DAI management, employees and others to work together to address fraud, sexual misconduct, discrimination, abuse, and other misconduct on projects and in the workplace while cultivating a positive work environment. It’s a ‘speak up’ line. It’s here for you.

Why do we need a system like the Speak Up Line?

• Our employees and our partners are our most important assets. By creating open channels of communication, we promote a positive work environment and professional relationships. It’s what makes us successful.
• An effective reporting system supports our other efforts to foster a culture of integrity, respect, and ethical decision-making.
• Accountability: The Speak Up EthicsPoint service also provides an opportunity for people in the communities where we work to raise concerns about DAI employees.

May I report using either the Internet or the telephone?

Yes. The Speak Up Line enables you to raise a confidential, anonymous question or concern via either the telephone or the Internet.

What types of situations should I report?

The Speak Up Line allows employees, partners, or community members to raise concerns about any violation of our stated Code of Business Conduct and Ethics, or other concerns they may have.

If I see something, shouldn't I just raise it with my manager, security, or human resources and let them deal with it? Or raise it with the local DAI office?

If you are a DAI employee, we expect you to report behavior that you believe may violate our code of conduct. Ideally, you should bring any concerns forward to your direct manager, other members of our management team or the Ethics and Compliance Officer, Global Director of Safeguarding, Global Head of Diversity, Equity, Engagement & Inclusion (DEEI) or Human Resources (HR). We recognize, however, that sometimes you may want to report anonymously. If so, we would much rather you raise your concern anonymously than keep it to yourself. If you see something, speak up, say something.

If you are not a DAI employee, the Speak Up Line is here for you, too. You can choose how you raise a concern with DAI by either talking to someone at DAI or using the Speak Up Line.

Why should I report what I know? What’s in it for me?

We all have the right to work and live in a positive environment and with that right comes the responsibility of acting in an ethical, respectful manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. Misconduct can threaten the success of our work and the trust our clients and communities have in DAI. If you raise a concern, it means we can take action. If we don’t know about it, we can’t do anything about it.

Does DAI management really want me to raise my concern?

We certainly do. In fact, we need you to report. You know what is going on in our company - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Quickly raising your concern can help limit the impact on the company, community, and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

Where do these reports go? Who can access them?

Reports are entered directly on the Speak Up Line secure server managed by Ethicspoint. These reports are available only to specific individuals within DAI who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these recipients has had training in keeping these reported concerns in the utmost confidence.

• Ethics and Compliance questions and concerns are directed to Ethics and Compliance Officers.
• Safeguarding and Sexual Misconduct questions and concerns are directed to the Global Director of Safeguarding.
• Discrimination, Harassment and Microaggression questions and concerns are directed to the Global Head of DEEI.
• Harassment, Bullying and Human Resource matters, questions and concerns are directed to the Heads of HR in the respective geographic locations.

Isn’t this system just an example of someone watching over me?

No. The Speak Up Line is a positive aspect of our overall philosophy that allows us to ensure a safe, secure, ethical, and respectful workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. Effective communication is critical in today’s workplace, and this is a great tool to enhance that communication.

We have carefully chosen the best and easiest reporting tool to meet our compliance obligations and maintain a positive working culture.

It is my understanding that any concern I send from a company computer generates a server log that shows every website that my PC connects with. Won’t this log identify me as the report originator?

The system does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to the EthicsPoint service is available.

If you feel uncomfortable submitting a concern on your work PC, you have the option of using a PC outside our work environment (such as one located at an Internet café or at a friend’s house) through the EthicsPoint secure website. Many people choose either this option or use the toll-free number.

Can I raise a concern from home and still remain anonymous?

A report from home, a neighbor’s computer, DAI’s VPN, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint Speak Up system strips away Internet addresses so that anonymity is totally maintained.

I am concerned that the information I provide to the Speak Up Line will ultimately reveal my identity. How can you assure me that will not happen?

The Ethicspoint Speak Up system protects your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident. For example, “My line manager, John Smith…” or “In my 33 years working for DAI…”.

Is the telephone toll-free Speak Up Line confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the Speak Up web site. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my raised concern?

There is a section in the form to identify yourself if you wish.

I am aware of some individuals acting unethically, but it doesn't affect me. Why should I bother raising a concern?

DAI promotes ethical behavior. All unethical conduct, at any level, ultimately hurts DAI and all employees, including you. Lapses in ethics can have disastrous effects on companies and their work. If you know of any incidents of misconduct or ethical violations, consider it your duty to yourself, your co-workers and to those we are helping to raise a concern.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

Submit an inquiry or a concern. The Speak Up Line can help you prepare and submit your concern so that it can be properly understood. We would rather you raise a concern about a situation that turns out to be harmless than let possible unethical behavior go unchecked.

What if my boss or other managers are involved in a violation? Won’t they react by trying to cover it up?

The Ethicspoint Speak Up system and report distribution ensure that implicated parties are not notified or granted access to reports in which they have been named. The protection and well-being of the reporter and any victims is a paramount consideration. DAI has a strict non-retaliation policy.

What if I remember something important about the incident after I submit my concern? Or what if the company has further questions for me on the concern I’ve raised?

When you submit a concern at the Speak Up web site or through the telephone line, you receive a unique, randomized number called a “Report Key” and you are asked to choose a password. You can return to the EthicsPoint Speak Up system again either by Internet or telephone and access the original submission to add more detail or answer questions posed by DAI. We strongly suggest that you return to the site in the time specified to answer follow-up questions. You and DAI now have entered into an “anonymous dialogue,” where situations can be identified and resolved, no matter how complex.

Are these follow-ups on submissions as secure as the first one?

All the Speak Up correspondences are held in the same strict confidence as the initial submission, continuing under the cover of anonymity.

What if I lose my Report Key or forget the Password I created?

That’s okay. To ensure that security and confidentiality are maintained, if you lose your report key or password, you will need to file a new submission. Mention in the new submission that it is related to a concern or question you previously submitted.

Can I still submit a concern or question if I don’t have access to the Internet?

You can file a Speak Up Line concern or inquiry from any computer, smartphone or other device that can access the Internet. If you don’t have access to or are uncomfortable using the internet, you can call the Speak Up toll-free line, which is available 24 hours a day, 365 days a year.

I am a victim of sexual misconduct, discrimination or bullying. Do I have to raise a concern?

We understand that there are reasons why people who are victims of misconduct may be reluctant to raise a concern. We want to assure you that your concern will be treated confidentially, limiting involvement to only those managers who need to know; that we take all these concerns seriously; that we put your welfare and safety first; and that your concern will be dealt with by someone with many years’ experience and training in the issues. You may find it helpful to go to the Safeguarding Frequently Asked Questions for more details.

I am embarrassed.

It’s natural to feel embarrassed when you’re raising a concern about sensitive issues. We promise to deal with your concern with respect and consideration and in a straightforward manner.

I’m a DAI employee – will Human Resources know that I have raised a concern? I don’t want to get a reputation.

We operate on a ‘need to know’ basis, limiting the involvement to only those managers who will be directly involved in resolving the concern. If you’re a victim, no-one even needs to know your identity.

DAI also has a strict non-retaliation policy. DAI will not discharge, demote, suspend, threaten, harass, or in any manner discriminate against any person in terms and conditions of employment based upon any lawful actions that person may take in making a good-faith report of ethics or compliance concerns.

I don’t think anyone will pay attention to me. The person I’m raising a concern about is more senior than me.

Your concern is important to us, no matter who you are or who you are raising a concern about. We only care about the behavior, not the status of the people involved. We believe it is important that you feel you can raise your concern, confident that we will handle the matter carefully and with your welfare and safety as our top consideration.